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Tuesday, March 31, 2009

Some Thoughts on the IRS Voluntary Disclosure Program for Offshore Accounts (3/31/09)

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I have outlined the key points of the IRS' new initiative here . (IRS documents related to the initiative may be accessed here .) I offe...
6 comments:
Saturday, March 28, 2009

Tax Due - Tax Loss; Critical Differences For Sentencing (3/28/09)

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Tax Due - Tax Loss; Critical Differences For Sentencing I have previously discussed here and here the element of tax due and owing for ta...
7 comments:
Friday, March 27, 2009

IRS Offshore Bank Account Initiative -- Key Points (3/27/09)

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The key points of the IRS initiative are: 1. Taxpayer must file amended income tax returns or, if no original income tax returns were file...
Thursday, March 26, 2009

Govt: Let's Really Punish these KPMG Shelter Defendants

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I discussed earlier today one aspect of the Government's Sentencing Submission in United States v. Larson (SD NY No. S1 05 Cr. 888 (LA...

IRS Expected to Announce Inducements for Offshore Account Holders (3/26/09)

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The WSJ reports here and the New York Times reports here that the IRS will announce today that it is dealing on the offshore accounts. I ...

DOJ Policy on One Book Rule and Ex Post Facto

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The Sentencing Guidelines provide that the Guidelines to apply are the Guidelines "in effect on the date the defendant is sentenced....
Tuesday, March 17, 2009

Offshore Funds - How Not to Respond to the IRS Risk

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We have covered the Government's most recent initiatives involving U.S. taxpayers with offshore funds and noted that coming clean fast i...
4 comments:
Friday, March 13, 2009

Chipping Away at Tax Haven Secrecy

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It is no secret that tax haven banks, enabled by their tax haven countries, assist U.S. taxpayers and other persons of varied citizenship to...

Make Sure You Have Your Fees Covered

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This article from the WSJ Law Blog is a good reminder for lawyers playing in this and related fields (e.g., money laundering). The article...

Scoping the Conspiracy - Concealment Money Laundering & Tax Reporting (3/13/09)

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Conspiracy is all about the charged agreement -- the parties' contract. A critical element of the agreement is its scope. What was the o...
Thursday, March 12, 2009

Do the Sentencing Guidelines Matter Anymore - Relevance of Madoff

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This blog is principally targeted to the Tax Fraud class that Larry Campagna and I teach at UH Law School but other blog readers may also fi...

Act of Production Doctrine and Particularity (3/12/09)

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In our University of Houston Tax Fraud class last night, one of the topics we covered was the Fifth Amendment privilege in connection with c...
6 comments:
Monday, March 9, 2009

Boulware Wins the Battle Only to Lose the War (3/9/09)

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In Boulware v. United States, 552 U.S. 421 (2008) , here , the Supreme Court rejected the Ninth Circuit's holding that a dividend requi...
2 comments:

A Tax Crimes Fable - Plea Dilemmas for the Innocent Defendant (3/9/09)

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Once upon a time a major accounting firm looking for revenue and thus profits began a tax shelter operation. The tax shelter operation invol...

A Taxpayer Defendant Victory

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Although a bit old news now (it happened last week), I post this item to make sure readers know about it if they have missed other news sour...
Sunday, March 1, 2009

Tax Scandals of the Rich and Famous

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I picked up from the Tax Prof List Serv this " lineup " of prominent Americans with tax woes. Not all of these should or will end...
Friday, February 27, 2009

The Mega Trial and Jurors' Attention Span

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Although not a tax crimes case and, indeed, not a criminal case at all, a recent SEC civil case is interesting for the criminal tax lawyer i...
Wednesday, February 25, 2009

Tax Shelter Penalties -- Other Costs of Being a Player

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Practitioners tend to focus principally on civil and criminal tax penalties when trying to discourage clients (taxpayers or promoters) from ...